Correspondence 0001965132-24-000011 from Landa Financing LLC (CIK 0001965132)
Landa Financing LLC (CIK 0001965132)
Date: June 7, 2024 · CIK: 0001965132 · Accession: 0001965132-24-000011
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File numbers found in text: 024-12193
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CORRESP
1
filename1.htm
June 7, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance – Office of Real Estate & Construction
100 F Street, N.E.
Washington, D.C. 20549-3010
Re: Landa Financing LLC
Offering Statement on Form 1-A
Filed May 15, 2024
File No. 024-12193
Dear Staff of the Division of Corporation Finance:
This letter is submitted on behalf of Landa Financing LLC (the “Company”) in response to a comment
letter from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) dated June 6, 2024 (the “Comment Letter”) with respect to the
Company’s Offering Statement on Form 1-A filed with the Commission on May 15, 2024 (the “Offering
Statement”).The Company is concurrently filing an amended Offering Statement on Form 1-A (the
“Amended Offering Statement”), which includes changes in response to the Staff’s comments as well as
other revisions.
For your convenience, the Staff’s comments have been reproduced in bold italics herein with responses
immediately following each comment. Unless otherwise indicated, page references in the Staff’s
comments refer to the Offering Statement, and page references in the responses refer to the Amended
Offering Statement. Defined terms used herein but not otherwise defined have the meanings given to
them in the Amended Offering Statement.
Post-Qualification Amendment to Offering Statement on Form 1-A filed May 15, 2024
Part I
Item 3. Application of Rule 262, page I-1
1. We note that the box is checked indicating that disclosure under Rule 262(d) is
included in Part II of the offering statement; however, no disclosure is provided.
Please remove the check mark or revise your disclosure, as applicable.
Response to Staff Comment No. 1
In response to the Staff’s comment, the Company has revised Part 1 and removed the check
mark indicating that disclosure under Rule 262(d) is included.
Item 4. Summary Information Regarding the Offering and Other Current or Proposed Offerings, page I-1
2. We note that the box is checked indicating that disclosure under Rule 262(d) is
included in Part II of the offering statement; however, no disclosure is provided.
Please remove the check mark or revise your disclosure, as applicable.
Response to Staff Comment No. 2
n response to the Staff’s comment, the Company has revised the Amended cover page of the
Offering Circular and Part I-1 to include the dollar amount of the shares currently being offered
and the amount sold within the last 12 months.
Sincerely,
LANDA FINANCING LLC
By:
Landa Management LLC, as manager
By:
Landa Holdings, Inc., as member manager
By:
/s/ Yishai Cohen
Name:
Yishai Cohen
Title:
Chairman, Chief Executive Officer and
President